The Centers for Medicare & Medicaid Services recently released its proposed CY 2026 Home Health Prospective Payment System and related DMEPOS rule. While intended to update payment systems and ensure program integrity, several provisions could have serious consequences for home health, hospice, and home medical equipment providers in Michigan.

On behalf of nearly 300 members across the state, the Michigan HomeCare & Hospice Association submitted formal comments to CMS urging revisions that would protect access to care for patients and support the sustainability of providers.

Major Concerns:

Deep Payment Reductions
At the heart of the proposed rule is a 9% reduction to home health reimbursement. This includes a permanent 4.059% “behavioral adjustment” and a temporary 5% “clawback,” layered on top of case-mix recalibration, wage index changes, and quality reporting updates. For Michigan agencies already stretched by workforce shortages and rising costs, these cuts could jeopardize their ability to deliver cost-effective care at home.

Case-Mix Recalibration
CMS proposes to adjust PDGM case-mix weights using 2024 claims data. This raises significant concerns for Michigan, where agencies care for large numbers of patients with heart failure, COPD, diabetes, and complex post-surgical recovery needs. If recalibration fails to capture this complexity, reimbursement could fall short for precisely the patients who most need intensive home health and hospice care.

Quality Reporting and Certification
While MHHA supports efforts to improve quality reporting, rapid changes to HHCAHPS and OASIS risk disrupting care delivery if not implemented thoughtfully. Similarly, expanding provider eligibility for face-to-face certifications could help in some areas, but CMS must ensure teams in rural communities are not inadvertently excluded.

DMEPOS Challenges
The proposed rule includes new requirements for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies. These changes include adding continuous glucose monitors and insulin pumps to competitive bidding as rentals. While efficient in theory, contracting changes could leave rural Michigan counties underserved. Additionally, CMS proposes moving accreditation surveys from once every three years to annually; a shift that would impose significant administrative burdens without clear evidence of benefit.

MHHA’s Recommendations

In our comments, MHHA urged CMS to:

• Suspend or revise the behavioral adjustment and eliminate the 5% clawback.
• Engage stakeholders in refining PDGM recalibration to ensure complex patients are treated fairly.
• Phase in quality reporting changes with adequate training and support.
• Safeguard supplier access in competitive bidding rollouts.
• Apply prior authorization exemptions transparently and equitably.
• Retain the three-year accreditation cycle, or phase in any changes with strong evidence of need.

Protecting Care at Home

Michigan’s home health, hospice, and home medical equipment providers remain steadfast in their mission: delivering high-quality, compassionate care in the home. Policymakers must balance fiscal responsibility with equitable access to ensure patients across Michigan can continue to rely on care at home.

MHHA will continue to advocate for fair, sustainable policies, and we encourage our members and partners to stay engaged as CMS reviews public comments on this critical rule.